CLA-2-73:OT:RR:NC:N1:117

Ms. Ellen A. DiLapi
Sumitomo Corporation of Americas
1979 Marcus Avenue, Suite 220
Lake Success, NY 11042

RE: The tariff classification of steel mechanical tubing from Japan Dear Ms. DiLapi:

In your letter dated October 12, 2018, you requested a tariff classification ruling.

The product under consideration is seamless, cold-drawn, steel mechanical tubing used in airbag inflator applications. You plan to import the tubing in both alloy steel and nonalloy steel. The nonalloy steel tubing will have an inside diameter of 21.70 mm with a wall thickness of 1.83 mm. The alloy steel tubing will have an inside diameter of 17.35 mm with a wall thickness of 1.58 mm.

The applicable subheading for the nonalloy steel tubing will be 7304.31.6050, Harmonized Tariff Schedule of the United States (HTSUS), which provides for tubes, pipes and hollow profiles, seamless, of iron (other than cast iron) or steel: other, of circular cross section, of iron or nonalloy steel: cold-drawn or cold-rolled (cold-reduced): other: other. The rate of duty will be Free.

The applicable subheading for the alloy steel tubing will be 7304.51.5060, HTSUS, which provides for tubes, pipes and hollow profiles, seamless, of iron (other than cast iron) or steel: other, of circular cross section, of other alloy steel: cold-drawn or cold-rolled (cold-reduced): other: other: other. The rate of duty will be Free.

Duty rates are provided for your convenience and are subject to change. The text of the most recent HTSUS and the accompanying duty rates are provided at https://hts.usitc.gov/current.

On March 8, 2018, Presidential proclamations 9704 and 9705 imposed additional tariffs and quotas on a number of steel and aluminum mill products.  Exemptions have been made on a temporary basis for some countries. Quantitative limitations or quotas may apply for certain exempted countries and can also be found in Chapter 99. Additional duties for steel of 25 percent and for aluminum of 10 percent are reflected in Chapter 99, subheading 9903.80.01 for steel and subheading 9903.85.01 for aluminum. Products classified under subheadings 7304.31.6050 and 7304.51.5060, HTSUS, may be subject to additional duties or quota.  At the time of importation, you must report the Chapter 99 subheading applicable to your product classification in addition to the Chapter 72, 73 or 76 subheading listed above.

The Proclamations are subject to periodic amendment of the exclusions, so you should exercise reasonable care in monitoring the status of goods covered by the Proclamations and the applicable Chapter 99 subheadings.

This ruling is being issued under the provisions of Part 177 of the Customs Regulations (19 C.F.R. 177).

A copy of the ruling or the control number indicated above should be provided with the entry documents filed at the time this merchandise is imported. If you have any questions regarding the ruling, contact National Import Specialist Angelia Amerson at [email protected].

Sincerely,

Steven A. Mack
Director
National Commodity Specialist Division